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Federal Covid-19 Statistics as Science Advice: Trump Administration Violations of Federal Policy
Congress and the next Administration must act to protect the integrity of public health statistics
In the New York Times last Friday, Christopher Murray. director of the Institute for Health Metrics and Evaluation and a professor of health metrics sciences at the University of Washington, writes: “The Trump administration has declined to release critical data to outside public health experts that would enable them to devise strategies against the virus that has killed 223,000 Americans and counting.”
In principle, the withholding of such data is a violation of U.S. policy. In this post I’ll explain this violation. Under a Biden administration and a Democratic Congress, legislation should be enacted quickly to make the withholding of such public health statistics a violation of federal law. But before I get to remedies, this post explains some initial background context to understand how egregious the violations have been under the Trump Administration.
U.S. law and and policy governing the design, collection, processing, editing, compilation, storage, analysis, release, and dissemination of statistical information is complex (this NRC report provides an excellent introduction). Overall coordination of Federal statistics is the responsibility of the Office of Management and Budget, in the Executive Office of the White House.
To operate efficiently and effectively, the Nation relies on the flow of objective, credible statistics to support the decisions of individuals, households, governments, businesses, and other organizations. Any loss of trust in the accuracy, objectivity, or integrity of the Federal statistical system and its products causes uncertainty about the validity of measures the Nation uses to monitor and assess its performance, progress, and needs by undermining the public's confidence in the information released by the Government.
OMB recognizes over 100 different programs across the government that engage in statistical activities (and to be sure, there are many more than this), but it highlights 16 units in particular as ‘Federal Statistical Agencies.” Among these highlighted units is the National Center for Health Statistics (of the Centers for Disease Control within the Department of Health and Human Services).
OMB recognizes four overarching principles to guide the work of these agencies (which derive from guidance of the NAS, and OMB also emphasizes compatibility with the European Statistics Code of Practice and the U.N. Fundamental Principles of Official Statistics).
1. Relevance to Public Policy Issues. A Federal statistical agency must be in a position to provide objective, accurate, and timely information that is relevant to issues of public policy.
2. Credibility Among Data Users. A Federal statistical agency must have credibility with those who use its data and information.
3. Trust Among Data Providers. A Federal statistical agency must have the trust of those whose information it obtains.
4. Independence from Political and Other Undue External Influence. A Federal statistical agency must be independent from political and other undue external influence in developing, producing, and disseminating statistics.
Under OMB Statistical Policy Directive No. 1, the importance of independence from policy-making, partisan and political considerations is explicit:
It is paramount that Federal statistical agencies and recognized statistical units produce data that are impartial, clear, and complete and are readily perceived as such by the public. The objectivity of the information released to the public is maximized by making information available on an equitable, policy-neutral, transparent, timely, and punctual basis. Accordingly, Federal statistical agencies and recognized statistical units must function in an environment that is clearly separate and autonomous from the other administrative, regulatory, law enforcement, or policy-making activities within their respective Departments.
Ample evidence has emerged indicating that the Trump administration has violated its responsibility to “conduct objective statistical activities” within HHS. There are no shortage of examples. For instance, The New York Times needed to sue CDC in order to obtain Covid-19 data broken down by race. According to Pro Publica (see also this reporting by Science), last spring “the Trump administration stripped the CDC of its lead role in handling this vital hospital data” and then “in July told hospitals to stop reporting coronavirus data to the CDC.” The University of Washington’s IHME director Murray says that they have requested a range of important data related to the pandemic across the United States, “We have asked the C.D.C. for such data but have been told by officials that they cannot share it. These breakdowns are essential to make sense of what is happening.”
The evidence is overwhelming that the Trump administration, by interfering with the statistical work of career technical experts, has systematically and egregiously violated U.S. federal policy on statistical information in CDC. One result has been a remarkable decline in public trust in CDC. Another is that policy makers who rely on data from CDC do not have the information needed to inform public health decision making. Public health policy is consequently to some degree flying blind.
OMB has long understood why trust in statistics matters:
To be collected and used efficiently, statistical products must gain and preserve the trust of the respondent and user communities; data must be collected and distributed free of any perceived or actual partisan intervention. Widespread recognition of the Federal statistical system's policy-neutral data collection and dissemination fosters such trust. This trust, in turn, engenders greater cooperation from respondents and higher quality statistics for data users.
Fixing the violations of established statistical policies and practices by the Trump administration will require more than an election. It will, among other steps, require formalizing statistical practices in law that have heretofore been the domain of administrative guidance in the executive branch. For example, the attention and care to federal statistics associated with economic indicators must be extended to public health statistics. Fortunately, Congress has some legislative options that might be adapted to these issues (e.g., see my scientific integrity testimony from last year).
In coming posts I’ll discuss both the deeper background and history of statistics as a mechanism of science advice, as well as concrete proposals for the next Congress and administration to address the policy shortfalls revealed by the malevolence of the Trump administration.